Gulf, Colorado & Santa Fe Ry. v. Ellis

In Gulf, Colorado & Santa Fe Ry. v. Ellis (1896) 165 U.S. 150, the court struck down a Texas statute that permitted successful tort claimants to recover attorneys' fees, if the suit had been brought against a railroad corporation. The court suggested several possible purposes and resultant classifications for such a statute. Its goal might have been to ensure that tort-feasors would compensate their victims, but then the statute should have applied against all tort-feasors. ( Id., at pp. 156-157.) Its goal might have been to place a higher duty to pay such obligations on corporations because the government grants corporations special privileges, but then the appropriate category would have been all corporate tort-feasors. The goal might have been to extract a higher duty from quasi-public corporations, but then the appropriate category would have been all quasi-public corporate tort-feasors. ( Id., at pp. 156-157.) The court concluded that "in all cases it must appear not only that a classification has been made, but also that it is one based upon some reasonable ground -- some difference which bears a just and proper relation to the attempted classification -- and is not a mere arbitrary selection." ( Id., at pp. 165-166.) Utilizing these principles the court held that the statute was unconstitutional.